- 5 - Federal income tax returns for the years in issue. During 1983 or 1984, petitioner and Ms. McNamara3 organized the corporation.4 The corporation engaged in the business of installing heavy machinery and equipment used by its customers in their manufacturing businesses. The corporation maintained a business checking account at PSFS Bank. During the years in issue, all of the outstanding shares of the corporation’s common stock were held in Ms. McNamara’s name. Both petitioner and Ms. McNamara considered petitioner to be at least a part owner of the corporation during the years in issue. Petitioner and Ms. McNamara decided to issue all of the corporation’s stock to Ms. McNamara for various business and personal reasons. Petitioner stated to respondent’s agents that he and Ms. McNamara had the corporation’s common stock issued to Ms. McNamara because the regulations of the union of which petitioner was a member prohibited its members from owning corporate stock. During the years in issue, petitioner and Ms. McNamara were employees of the corporation. Petitioner considered his position in the corporation equivalent to that of a chief executive officer, and he made all significant business decisions for the 3 At the time the corporation was organized, Ms. McNamara was known as Bonnie E. Moran. 4 The corporation also did business as Moran General Contractors, Inc.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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